While the Constitutional Chamber is retained as such, the draft amendments to Article 97 appear to considerably weaken its institutional role as an effective organ of judicial constitutional review by essentially turning it into a mere advisory body. This would also appear to be the intent of the legal drafters, as the Explanatory Statement to the Draft Amendments states that the Constitutional Chamber should be a “body secondary to the President and the Jogorku Kenesh which cannot and should not have more powers than the people or their representatives”. While there are various models of constitutional review across the OSCE and the Council of Europe regions, such review should, as a general rule, take place outside the legislative and executive branches of power. Moreover, democratic systems are built on the separation of three equal branches of power, including, next to the executive and the legislative, also the judiciary, with the two latter exercising special oversight functions. Turning the Constitutional Chamber into a body that is secondary to the executive and legislative powers would thus constitute a worrying development, all the more given the importance of a constitutional court for the overall functioning of democratic institutions, the protection of human rights and the rule of law in a country.